COMPLAINT FOR PATENT INFRINGEMENTPage 27.
Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391 and1400(b) because Raymarine regularly conducts business in this judicial district and/or becausecertain of the acts complained of herein occurred in this judicial district.8.
FEC’s subsidiary in the United States is FUSA
FUSA’s activities, which
include sales, main
tenance and repair of FEC products, are essential to FEC’s operations in theUnited States. Accordingly, FUSA’s proximity to this district makes it a convenient forum.
On July 4, 2000, the USPTO issued U.S. Patent No. 6,084,565 titled
“the ’565 patent”). A true and correct copy of the ’565
patent is attached hereto as Exhibit A.10.
On January 9, 2007, the USPTO issued U.S. Patent No. 7,161,561 titled
). A true and correct copy of the
561 patent isattached hereto as Exhibit B.11.
565 patent and
561 patent are henceforth referred to as the
FEC is the owner of all right, title, and interest in and to each of the patents-in-suit with full and exclusive right to bring suit to enforce this patent, including the right torecover for past infringement.
COUNT IINFRINGEMENT OF THE
FEC and FUSA (collectively
), realleges and incorporates herein theallegations of the preceding paragraphs of this Complaint as if fully set forth herein.14.
Upon information and belief, in violation of 35 U.S.C. § 271, Raymarine hasinfringed and is continuing to infringe, literally and/or under the doctrine of equivalents, the
565 patent by practicing claims 16-20 of the
565 patent in the manufacture, use, offering for sale, sale, and/or importation of marine navigation and/or tracking products, including, but not